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There is also the worry that the costs could become so prohibitive that the effect could be that rather than encouraging more effective and wider regulation, particularly in respect to individual childminders, it could drive people underground as they decide they cannot afford to participate in the system. The Executive say they will continue to subsidise childcare regulation, which is intended to mitigate the effects of such increases. The fee-charging system also seems quite bureaucratic, since the Executive will have to increase local authority funding in order for the local authorities to pay it back to the Commission (either directly or through private and voluntary care providers). The Health & Community Care Committee felt they had not heard a satisfactory answer from the Executive to these concerns on funding, and intend pressing the Executive further on this as the Bill proceeds. Number of Inspections Real concern has been expressed at the reduced requirement in the Bill for just one mandatory inspection a year, when local authorities are currently expected to make at least two inspections a year (most make more). Thus "with the Executive's proposals, it appears that providers may well receive fewer inspections each year at an increased price" (H&CC Committee). Staffing and Structure Concerns have been expressed about ensuring that inspection and other staff are given proper guarantees when they transfer to the new bodies. In particular, there are doubts about the practicality of having only five regional centres, which would lose the local relationships which currently stop the system becoming faceless. Omissions Adoption and fostering services have not been included in the draft Bill, but there have been promises of an amendment to bring them within the new system. The Minister has stated that "Although the commission will regulate fostering and adoption agencies and the arrangements that local authorities and voluntary and other organisations make, it will not regulate foster homes or adoption families". Concern has also voiced at the omission of required registration for au pairs, nannies and nanny agencies. With controversy still raging around implementation of the Sutherland report, the H&CC Committee are concerned that there remain some problems of definition within the Bill - not least in respect of personal care. A similar Act passed in Westminster established the office of a Children's Commissioner for Wales and a Children's Rights Director in England. CoSLA and others believe that the Bill should include a provision for the establishment of an independent Children's Commissioner in Scotland; the Parliamentary H&CC Committee, while sympathetic to the idea, recognise that this Bill may not be the place to introduce such a provision. Theological & Church Context The Church of Scotland's Board of Social Responsibility is the largest voluntary social care provider in Scotland, and other churches also run a range of care homes, etc. This is therefore a significant move, and one which has broadly been welcomed by the churches (although they have shared some of the concerns outlined above, particularly on funding). Both practice and theology would seem to demand support for measures designed to secure improvements in the quality of care provided for all those who are vulnerable, and proper safeguards against exploitation and abuse. While there is no detailed Biblical guidance on how such matters should be organised, caring in the name of Christ cannot be less "professional" (in the positive sense of meeting the highest standards), and we will no doubt want to continue to do pioneering and effective work that gives our best to loving our neighbour. That commitment will be the context of responses to this Bill.
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